NANO-CHECK AMI 2 IN 1 CARDIAC MARKER, CTNL AND MYOGLOBIN
Applicant
Nano-Ditech Corporation
Product Code
MMI · Clinical Chemistry
Decision Date
Oct 20, 2010
Decision
SESE
Submission Type
Special
Regulation
21 CFR 862.1215
Device Class
Class 2
Device Story
Nano-check AMI 3 IN 1 Cardiac Marker Test; lateral flow immunoassay for cardiac markers; modification involves removal of CKMB test line reagents; device remains unchanged in fundamental scientific technology; intended for professional use in clinical settings to aid AMI diagnosis.
Clinical Evidence
Bench testing only; verification and validation activities performed per design control requirements to confirm performance after reagent removal.
Technological Characteristics
Lateral flow immunoassay; qualitative detection; modified to remove CKMB reagents; fundamental technology unchanged from predicate.
Indications for Use
Indicated for the qualitative detection of cardiac markers in human blood samples to aid in the diagnosis of acute myocardial infarction.
Regulatory Classification
Identification
A creatine phosphokinase/creatine kinase or isoenzymes test system is a device intended to measure the activity of the enzyme creatine phosphokinase or its isoenzymes (a group of enzymes with similar biological activity) in plasma and serum. Measurements of creatine phosphokinase and its isoenzymes are used in the diagnosis and treatment of myocardial infarction and muscle diseases such as progressive, Duchenne-type muscular dystrophy.
Predicate Devices
Nano-check AMI 3 IN 1 Cardiac Marker Test (K050975)
Submission Summary (Full Text)
{0}
SPECIAL 510(k): Device Modification
OIVD Review Memorandum
To: THE FILE
RE: DOCUMENT NUMBER K102441
This 510(k) submission contains information/data on modifications made to the SUBMITTER'S own Class II, Class III or Class I devices requiring 510(k). The following items are present and acceptable (delete/add items as necessary):
1. The name and 510(k) number of the SUBMITTER'S previously cleared device, Nano-check AMI 3 IN 1 Cardiac Marker Test, k050975. (For a preamendments device, a statement to this effect has been provided.)
2. Submitter's statement that the INDICATION/INTENDED USE of the modified device as described in its labeling HAS NOT CHANGED along with the proposed labeling which includes instructions for use, package labeling, and, if available, advertisements or promotional materials (labeling changes are permitted as long as they do not affect the intended use).
3. A description of the device MODIFICATION(S), including clearly labeled diagrams, engineering drawings, photographs, user's and/or service manuals in sufficient detail to demonstrate that the FUNDAMENTAL SCIENTIFIC TECHNOLOGY of the modified device has not changed.
This change was for removal of CKMB test line reagents.
4. Comparison Information (similarities and differences) to applicant's legally marketed predicate device including, labeling, intended use, physical characteristics, and performance verification/validation information.
5. A Design Control Activities Summary which includes:
a) Identification of Risk Analysis method(s) used to assess the impact of the modification on the device and its components, and the results of the analysis
b) Based on the Risk Analysis, an identification of the verification and/or validation activities required, including methods or tests used and acceptance criteria to be applied
c) A declaration of conformity with design controls. The declaration of conformity should include:
i) A statement signed by the individual responsible, that, as required by the risk analysis, all verification and validation activities were performed by the designated individual(s) and the results demonstrated that the predetermined acceptance criteria were met, and
ii) A statement signed by the individual responsible, that the manufacturing facility is in conformance with design control procedure requirements as specified in 21 CFR 820.30 and the records are available for review.
6. A Truthful and Accurate Statement, a 510(k) Summary or Statement and the Indications for Use Enclosure (and Class III Summary for Class III devices).
The labeling for this modified subject device has been reviewed to verify that the indication/intended use for the device is unaffected by the modification. In addition, the submitter's description of the particular modification(s) and the comparative information between the modified and unmodified devices demonstrate that the fundamental scientific technology has not changed. The submitter has provided the design control information as specified in The New 510(k) Paradigm and on this basis, I recommend the device be determined substantially equivalent to the previously cleared (or their preamendment) device.
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